I. General AML Policies, Practices and Procedures:

Yes

No

1. Is the AML compliance program approved by the FI's board or a senior committee

X

2. Does the FI have a legal and regulatory compliance program that includes deignated officer that is responsible for coordinating and overseeing the AML framework?

X

3. Has the Fi developed written policies documenting the processes that they have in place to prevent, detect and report suspicious transactions?

X

4. In addition to inspections by the government supervisors/regulators, does the FI client have an internal audit function or other independent third party that assesses AML policies and practices on a regular basis?

X

5. Does the FI have policy prohibiting accounts/relationships with shell banks? (A shell bank is defined as a bank incorporated in a jurisdiction in which is has no physical presence and which is unaffiliated with a regulated financial group.)

X

6. Does the FI have policies to reasonably ensure that they will not conduct transactions with or on behalf of shell banks through any of its accounts or products?

X

7. Does the FI have policies covering relationship with Politically exposed Person (PEP's), thier family and close associates?

X

8. Does the FI have record retention procedures that comply with applicable law?

X

9. Are the FI's AML policies and practices being applied to all branches and subsidiaries of the FI both in the home country and in locations outside of that jurisdiction?

X

II. Risk Assessment

Yes

No

10. Does the FI have a risk-based assessment of its customer base and thier transactions?

X

11. Does the FI determine the appropriate level of enhanced due diligence necessary for those categories of customers and transactions that the FI has reason to believed pose a heightened risk of illicit activities at or through the FI?

X

III. Know Your Customer, Due Diligence and Enhanced Due Diligence

Yes

No

12. Has the FI implemented processes for the identification of those customer on whose behalf it maintains or operates accounts or conduct transactions?

X

13. Does the FI have a requirement to collect information regarding its customers' business activities?

X

14. Does the FI assess its customers' AML policies or practices?

X

15. Does the FI have a process to review and, where appropriate, update customer information relating to high risk client information?

X

16. Does the FI have procedures to establish a record for each new customer noting their respective identification documents and 'Know Your Customer' information?

X

17. Does the FI complete a risk-based assessment to understand the normal and expected transactions of its customer?

X

IV. Reportable Transactions and Prevention and Detection of Transaction with Illegally Obtained Funds

Yes

No

18. Does the FI have policies or practices for the identification and reporting of transactions that are required to be reported to the authorities?

X

19. Where cash transaction reporting is mandatory, does the FI have procedures to identify transactions structured to avoid such obligations?

X

20. Does the FI screen customers and transactions against lists of persons, entities or countries issued by government/competent authorities

X

21. Does the FI have policies to reasonably ensure that it only operates with correspondent banks that possess licenses to operate in their countries of origin?

X

V. Transaction Monitoring

Yes

No

22. Does the FI have a monitoring program for unusual and potentially suspiscious activity that covers funds transfers and monetary instruments such as travelers checks, money orders, etc.

X

VI. AML Training

Yes

No

23. Does the FI Provide AML training to relevant employees that includes:

• Identification and reporting of transactions that must be reported to government authorities.
• Examples of different forms of money laundering involving the FI's products and services.
• Internal policies to prevent money laundering.

X

24. Does the FI retain records of its training sessions including attendance records and relevant training materials used?

X

25. Does the FI communicate new AML related laws or changes to existing AML related policies or practices to relevant employees?

X

26. Does the FI employ third parties to carry out some of the functions of the FI?

X

27. If the answer to question 26 id yes, does the FI provide AML training to relevant third parties that includes:

• Identification and reporting of transactions that must be reported to government authorities.
• Examples of different forms of money laundering involving the FI's products and services.
• Internal policies to prevent money laundering.

N.A.

Space for additional information:
(Please indicate which question the information is referring to.) --------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------